Waverley Borough Council Committee System - Committee Document
Meeting of the Environment and Leisure Overview and Scrutiny Committee held on 05/06/2006
South East Plan
WAVERLEY BOROUGH COUNCIL
JOINT ENVIRONMENT AND LEISURE AND COMMUNITY OVERVIEW
AND SCRUTINY COMMITTEE
EXECUTIVE – 5TH JUNE 2006
SOUTH EAST PLAN: DRAFT PLAN FOR SUBMISSION TO GOVERNMENT
[Wards Affected: All]
Summary and purpose
The South East England Regional Assembly (SEERA) has prepared the new Plan for the region to be known as the South East Plan. This document will replace the current Regional Guidance set out in RPG9. It sets out the vision for the region through to 2026 and, once approved, local authorities and other government agencies will have to follow its principles and be guided by the plan in implementing regional strategies at a local level.
The South East Plan was approved by the Regional Assembly at its Plenary meeting on the 1st March 2006 and was submitted to the Government on 31st March. The formal consultation period commenced on 31st March and will continue to 23rd June. All responses must be submitted to the Panel Secretariat by 23rd June 2006.
This report deals with the South East Plan as it affects Waverley. A separate report, reported elsewhere on this agenda, relates to the issue of the Thames Basin Heaths Special Protection Area as it affects the South East Plan and has been prepared jointly by officers of all the fifteen authorities affected both directly and indirectly by the Special Protection Area. Together these reports set out the issues which could form the basis of the Council’s formal response.
A Special meeting of the Executive has been arranged to follow from the joint meeting of the Environment and Leisure and Community Overview and Scrutiny Committees. The views of the Executive will be forwarded to the Panel Secretariat.
There are extensive environmental implications. These set out in the report.
Social and Community implications
There are extensive social and community implications. These are set out in the report.
There are no direct e-government implications.
Resource and legal implications
There are no direct e-government implications.
A number of abbreviations and acronyms are used in this report. These are:-
Area of Outstanding Natural Beauty
Government Office for the South East
Local Development Documents
Local Development Framework
Section 106 agreement
Special Area of Conservation
South East Regional Assembly
South East Plan
Special Protection Area
Please also find a definition of affordable housing to assist with the areas discussed and considered in this report.
DEFINITION OF AFFORDABLE HOUSING
is housing that is provided with a subsidy for people who would otherwise not be able to afford a suitable home. It includes:
(a) Shared ownership housing- this can be new or existing housing that is made available on a part rent part sale basis. The occupier buys a percentage share of the property, with the remaining percentage being typically owned by a housing association (otherwise known as a registered social landlord). This category would include shared ownership housing provided for key workers.
(b) Social rented housing- this is housing for rent that is provided by the Council or a housing association at below market rents.
1. The South East England Regional Assembly (SEERA) has prepared the Regional Spatial Strategy for the region to be known as the South East Plan. This document has been prepared under the terms of the Planning and Compulsory Purchase Act 2004 and will replace the current Regional Guidance set out in RPG9. It sets out the vision for the region through to 2026 and, once approved, will become a legal document which local authorities and other government agencies will have to follow.
2. The South East Plan (SEP) was approved by the Regional Assembly (SEERA) at its Plenary meeting on 1st March 2006 and was submitted to the Government on 31st March. The formal consultation period commenced on 31st March and will continue to 23rd June.
3. This report deals with the South East Plan as it affects Waverley. A separate report relating to issue of the Thames Basin Heaths Special Protection Area (SPA) as it affects the SEP has been prepared jointly by all the fifteen authorities affected both directly and indirectly by the SPA. Together these reports set out the issues which could form the basis of the Council’s formal response.
4. The Examination in Public to test the Plan will start in November this year and is likely to be concluded in March 2007. GOSE’s comments, on behalf of Government, will be submitted by 23rd June deadline.
4. The Draft Plan comprises:-
an Executive Summary
the Core document
an Implementation Plan
a Monitoring Framework
a Sustainability Appraisal
a pre-submission Consultation Statement
5. The draft Plan builds on partial reviews in respect of transport, tourism, energy, minerals and waste published by the Government since RPG9 was published in March 2001. It also builds on strategies agreed for the two growth areas of Ashford and Milton Keynes/South Midlands.
6. Circular 01/2006 (Planning for Gypsy and Traveller Caravan Sites) was published in February 2006. This requires Regional Spatial Strategies to take a strategic view of Gypsy and Traveller needs in the region and identify the number of pitches required for each planning authority. The Circular acknowledges that full consideration cannot be undertaken in advance of Gypsy and Traveller Accommodation Assessments. The draft Plan therefore commits SEERA to undertake an immediate partial review of the SEP in relation to Gypsy and Traveller accommodation which it is anticipated will be completed by early 2008.
Waverley’s views at the Issues and Options stage
7. Members may recall considering a report in April 2005 on the Consultation on the Issues and Options. The Council’s views were forwarded to SEERA on 13th April 2005. A copy of the letter is attached at
8. Briefly, the Council’s views were:
a) the identification of the London Fringe as an area for significant growth was inconsistent with Government Policy and policies for the protection of the Green Belt in the Plan itself. The Council was concerned about the indirect adverse impact that this would have on adjacent areas, including Waverley;
b) there was a need for strategic policies and guidance for rural areas outside the sub-regions;
c) the policies in the plan should be amended to reflect the need to ensure that infrastructure for new development should precede that development. It was also felt that the Plan should provide more detailed strategic guidance for the areas in between the sub-regional areas with regard to infrastructure issues;
d) the Plan should more fully recognise “quality of life” issues, should avoid a “blanket prescription” to density and should identify criteria for differentiating between individual towns and areas within those towns that can take higher densities and those where lower densities are appropriate, leaving the detail to LDFs;
e) the Plan should specifically stress the importance of protecting Green Belt and AONBs;
f) the Plan should more adequately address the needs of affordable housing in the more rural parts of the region. In particular it should specify that the “affordable” element should be raised to 50% in all developments and the threshold for social housing should apply to every dwelling by some form of tariff payable to local authorities;
g) there should be a closer correlation between the SEP and the Regional Housing Strategy;
h) there should be a hierarchy of the towns listed in Policy TC2;
i) Farnham should not be included in the Western Corridor/Blackwater Valley sub-region; and
j) the Consultation process was inadequate.
Whether these views have been taken into account
9. The submission draft indicates that:
a) the London Fringe remains a significant area for growth and is a fundamental part of the overall strategy of the SEP;
b) there are no specific strategic policies/guidance for rural areas outside the sub-regions, it being felt that these issues are covered by the cross-cutting policies;
proposes a concordat between Government and the region to help address the infrastructure issue. This identifies the need for further investment in transport and affordable housing at the regional level and the need to ensure that funding mechanisms enable the delivery of infrastructure in a timely manner through:
i. sustained high levels of public investment;
ii. enhancement of S106 arrangements to fund sub-regional local infrastructure;
iii. extension of local tariff approaches;
iv. introduction of a Planning Gain Supplement;
v. creation of a Regional Infrastructure Fund.
also examines other mechanisms through which the objectives of the South East Plan can be delivered, including:
i. effecting behavioural change in travel, consumption and use of water and energy, including carbon fuels and production of waste;
ii. changing the regulatory frameworks to enable gas, water and electricity utilities to invest in anticipation of future growth;
iii. higher levels of investment in the maintenance of existing infrastructure;
iv. investment in new infrastructure.
Whilst fully in accordance with the principles of sustainability, it is central Government that sets these agendas and SEERA itself has only limited influence. There is, therefore a risk that much of the
is undeliverable without significant changes in regulation and legislation at Government level.
Notwithstanding this, the Plan is deficient in any specific commitment of resources/investment/funding allocations for the key infrastructure necessary to deliver the development allocations. There are, therefore, question marks over deliverability.
d) Whilst the overall regional target of 40 dwellings per hectare is retained, Policy H5 states that local authorities will reflect this target “with appropriate local variations” in their LDDs and that “positive measures to raise the quality of new housing, reduce its environmental impact and facilitate future adaptation…will also be encouraged”. The policy also stresses the need for local authorities to prepare design guidelines to encourage sustainable construction. It would, however, be preferable if the policy were to go further and require that new residential development integrates into its surroundings.
e) Policy CC10a states that Green Belts will be retained and supported and the opportunity will be taken to improve and access as part of initiatives to improve the urban rural fringe. Policy CC10b sets out criteria for the identification of strategic gaps and requires that development within those gaps should only be permitted where it would not compromise, individually or cumulatively, the fundamental integrity and purpose of the gap. It is felt that this policy should be strongly supported. Policy C2 indicates that, within AONBs, priority should be given to the conservation and enhancement of their natural beauty and that within this context, the emphasis should be on small-scale proposals that are sustainably located and designed;
f) Policy H4 specifies that Local Development Documents (LDDs) will set targets for the provision of affordable housing, taking account of the results of housing need and market assessments and having regard to the overall regional target that 25% of all new housing should be social rented accommodation and 10% other forms of affordable housing;
g) the transference of the Regional Housing Board (which is responsible for the production of the Regional Housing Strategy) to SEERA should secure a closer correlation between the SEP and the Regional Housing Strategy;
h) Policy TC2 now identifies primary and secondary regional centres. Farnham is included in the list of secondary centres. The policy states that there are “many other centres…that meet local needs” and that LDDs “should identify and develop policies for centres within their areas”;
i) Farnham is not included in the Western Corridor/Blackwater Valley sub-region; and
j) whilst the Consultation process at the Issues and Options stage was considered inadequate, there have also been deficiencies in the current consultation. The sister report on the SPA issue explains that officers of the fifteen authorities affected by the Thames Basin Heaths SPA are concerned that the consultation process currently under way does not accord with the statutory requirements. Regulation 13(2) of the Town & Country Planning (Regional Planning) Regulations 2004 indicates that when consultation on a revision to the Regional Spatial Strategy commences, each local planning authority must make copies available from its principal offices. In Waverley’s case copies of the SEP were not available from the start of the consultation period (31st March 2006). Indeed officers did not receive the documents until a few days before Easter, nearly two weeks into the Consultation period.
Furthermore, whilst 12 weeks’ consultation has been allowed on the SEP, part of this period overlapped with the Easter Holidays and with the run-up to local government elections in a number of authorities. Regulation 13(5)(b) allows the regional planning body to increase the period for consultation to compensate for this and it is noticeable that the Government avoids election periods when it seeks views from the wider community on other documents. The Government should have followed the same principles for the SEP. This would have ensured better compliance of the SEP with PPS1. An extension to the timing would have been appropriate as it would have enabled this Council and others greater time to ensure community involvement in the process, as was the case at the Issues and Options stage.
10. Members will recall the debate on the Housing Allocation Distribution in October last year. A copy of the letter to the County Council of the 26th October 2005 is attached at
. Briefly, the Council expressed the following views:
a) to support the proposed regional growth levels (28,900 dwellings per annum for the South East and 220 for "Rest of Surrey") in the current South East Plan (SEP);
b) to support the focus on growth areas and in hubs in sub-regional areas;
c) to object strongly to the 245 dwellings per annum proposed for Waverley;
d) strongly urge the adoption of a figure for Waverley that is below 220 a year;
e) stress Waverley’s central corporate objective of providing affordable housing and stress that a "windfall" based approach is not as efficient in delivering affordable housing as allocating growth in proposals that have a substantial critical mass; and
f) express concern that Surrey is focussing its infrastructure provision policies on the "hubs" with no prospect of funds for infrastructure improvements in Waverley.
11. Policy H1 indicates that provision will be made for an annual average of 28,900 net additional dwellings between 2006 and 2026. The total annual figure for Surrey is 2,360 (47,200 over the full plan period) and that Waverley’s annual average is 230 dwellings, providing a total of 4,600 during the plan period. The overall regional housing allocation of 28,900 dwellings per annum includes an allowance to address the backlog of unmet housing need that existed in the South East in 2001.
12. Whilst the overall total housing allocation and the broad distribution in Policy H1 could be supported, that support should be conditional upon the following factors:
The delivery of the right infrastructure at the right time is fundamental to the delivery of the South East Plan. Unless there is clear commitment to the delivery of infrastructure, the South East Plan will not be 'sound'. Whilst there is the physical capacity within Surrey to meet the proposed housing requirement, technical work undertaken by the local authorities together with responses to the public consultation, highlighted significant concerns about the ability of the social, community, transportation and environmental infrastructure (water supply; sewerage provision; educational and health service provision; and the inadequacy of the public transport network) to support this level of development. Work undertaken by Roger Tym and Partners for the South East Counties highlighted the existence of a shortfall of £1.9bn in infrastructure investment to deliver the 28,900 annual dwelling requirement in the South East Plan. Within Surrey, the Sub-Regional Investment Framework identifies a significant need for additional investment in infrastructure to meet emerging housing needs, with further funding clearly needed to address existing shortfalls in provision.
Thus, delivery of the H1 allocation will require significant additional investment in infrastructure. A particular concern is that a significant element of the overall housing allocation in Surrey is to be delivered through development on smaller sites within the urban area. There is a need to ensure that the cumulative impact of small-scale development on infrastructure provision is addressed effectively. Policy LF5 of the draft SEP indicates that it is likely that this will require the introduction of a tariff-based approach to delivery. However, as indicated above, without changes in national legislation and regulation it is questionable that this can be delivered. The SEP, therefore should provide more certainty on the delivery of infrastructure proposals.
A joint response on the SPA has been prepared by the 15 local authorities directly affected by the Thames Basin Heaths (See accompanying report). This separate response addresses detailed issues, but the impact of English Nature’s draft Delivery Plan on potential housing allocations needs to be highlighted within the response on H1.
The current uncertainty surrounding the impact of the SPA is blocking planning applications for residential development across much of the west of the county, including in Farnham. Failure to satisfactorily resolve the SPA issue could potentially prejudice the planned allocation of over 5,000 dwellings within Surrey Heath, Guildford, Woking, Runnymede, Waverley and parts of Elmbridge. This has 2 potential consequences:
i) either the total housing allocation for Surrey should be reduced to reflect the constraints imposed by the SPA; or
ii) any shortfall in the western part of the county should be ‘made up’ through higher levels of provision elsewhere in Surrey. This would require substantial re-assessment of potential land supply, infrastructure provision and future requirements and a full sustainability appraisal of the implications.
The implications of the current uncertainty surrounding the SPA therefore could impact on a much wider area than the 15 most directly affected authorities. It is therefore appropriate to highlight issues arising from a potential increase in allocations in those districts and those parts of districts outside the 5km buffer zone. The implications of this are:
i) further investment in infrastructure;
ii) potential further intensification of development in urban areas outside the affected areas;
iii) use of existing “reserve” housing sites; and
iv) development on “greenfield” or other less sustainable sites.
The response to H1 should also refer to the potential impact of SAC designation on future development proposals. This is becoming a key issue in Runnymede and could, potentially, become an issue in Waverley and reinforces the need for a thorough Appropriate Assessment.
Thames Basin Heaths SPA
13. The report on the Thames Basin Heaths SPA as it affects the SEP, prepared jointly by officers from the fifteen affected authorities, identifies that those policies and parts of the draft Plan relating to the Thames Basin Heaths SPA and its impact on the housing strategy and allocations have not been proven to be sound and the housing requirements have not been shown to be deliverable. For these reasons the Plan fails the soundness criteria on a number of counts.
here is concern that the 3% per annum economic growth predicted in the South East Plan is realistic. Firstly it is questionable whether a 3% per annum growth rate will be achieved when it has only achieved 2.75% between 1989 and 2000 and longer run growth in the UK economy has only been 2% per annum. Secondly, disparities between the regions will widen further if higher levels of growth are pursued in the South East. Thirdly, the promotion of higher levels of economic growth in the 'overheated' parts of the South East will only exacerbate traffic problems, shortages of affordable housing, labour and skills shortages and degradation of air quality, natural resources and the high quality environment of the region.
15. More emphasis therefore should be put on sustainable levels of economic growth and the encouragement of economic growth through e- business which can be delivered through remote/tele-working and which will reduce travel demands and congestion.
Gypsies and Travellers
16. The section on Gypsies and Travellers referred to in para 6 above states that Bucks, Hants, Surrey and Kent contain a significant proportion of authorised caravans. What the text does not point out is that Surrey and Kent between them provide nearly 52% (Kent 27%, Surrey 25%) of all the authorised caravan sites in the South East region and, proportionately, the shortfalls in Surrey are less than many other counties/unitaries. There is concern that if this statement does not go unchallenged, we may see more pressure on Surrey to accommodate more gypsies and travellers when the review is undertaken.
17. The South East Plan is very long, insufficiently focused in places and not easy to use. Much does not add anything to Government Guidance and does not indentify what is 'south east specific'. A number of policies are little more than statements of general intent (e.g. Policies CC1 and CC7). It should be radically shortened, use a unique paragraphing system, keep its focus on the strategic and should not seek to micro-manage every aspect of development in the region. Where additional responsibilities are placed on local authorities, it should acknowledge the resource implications that these will have.
18. There is concern that a number of policies are inadequately framed to provide a robust and implementable basis for Local Development Frameworks. Specifically
(a) Policy RE2 should make it clear that industrial development should be steered away from the Green Belts, AONBs and other sensitive areas;
b) Policy T1 should recognise that the 'rebalancing of the transport system in favour of non-car modes' cannot be achieved everywhere. The policy should be caveated to recognise that the private car will continue to provide the primary mode of travel in rural areas;
(c) Policy TC2 should state that in addition to carrying out regular assessments of Town Centres, local authorities should also define the role of their centres not all centres should be seen to provide similar levels of facilites; and
(d) Policies TSR2 and TSR5 should be amended to reflect more clearly national policy and to provide a more balanced strategic framework for LDDs.
It is recommended that the above points form the basis of the Council’s representations to the South East Plan submission draft.
SEERA: Submission Draft South East Plan – March 2006
Name: Peter Hartley